1J Analysis of Section 503 AAP: Review of Online Application Process

The contractor is required to provide necessary reasonable accommodation to ensure applicants and employees with disabilities receive equal opportunity in the operation of personnel processes, including an equal opportunity to apply and be considered for employment. Therefore, in addition to reviewing a contractor’s Section 503 AAP as part of the desk audit, COs must review the contractor’s online application system (electronic or web-based) to ensure that it provides a means for contacting the contractor, other than through the online system, to request a reasonable accommodation to apply for the job. Applicants may need this contact information if they cannot use the online application system because of a disability. At a minimum, this information must include the name and phone number or email address of the person (or office) to whom a request for an accommodation should be made. The contact information need not mention the words “reasonable accommodation,” though it is a best practice to do so. COs will document the results of this analysis in the Case Summary and Recommendations section of the SCER. Contractors are also encouraged to make their information and communication technologies generally accessible. This is so even in the absence of a reasonable accommodation request. Doing so will minimize, but may not eliminate, the need to make individual reasonable accommodations.